Doing business overseas

1. [Approach](https://library.croneri.co.uk/po-heading-id_tHSfvaiAI0KKadGly8BpZA)

1.1. No taxable presence

1.2. Taxable presence

1.3. Dictated by local regulatory, commercial or practical considerations?

2. [Meaning of permanent establishment (PE)](https://library.croneri.co.uk/po-heading-id_He0U9BVD0k-KXXKWqJexfg)

2.1. Fixed place of business

2.1.1. Ancillary exceptiions

2.2. Agent concludes contracts

2.2.1. Exception for independent agents

2.3. BEPS project leading to change in PE definition

3. [Taxation of PE](https://library.croneri.co.uk/po-heading-id_tHSfvaiAI0KKadGly8BpZA)

3.1. UK parent has access to PE's early year losses

3.2. Local corporate tax (CT) on profits of PE

3.3. UK CT on profits of PE (credit for foreign tax)

3.4. Possible election for branch exemption or conversion to subsidiary (when profitable)

4. [Other tax issues relevant to PE/subsidiary](https://library.croneri.co.uk/po-heading-id_ZQOf6ibl2UOWwy4Ib-coiA)

4.1. Deductibility of finance costs

4.2. Transfer pricing

4.3. CFC rules; diverted profits tax

4.4. Withholding taxes (interest/royalties)

4.5. Ease/difficulty of converting branch to subsidiary

5. [Taxation of local subsidiary](https://library.croneri.co.uk/po-heading-id_EfKO1DqV30Wq3wThsaZBTQ?referral_nid=26205416)

5.1. Losses may be locked in (unavailable to parent)

5.2. Local corporate tax on profits

5.3. No UK CT on subsidiary's profits

5.3.1. Same result as for branch exemption

5.4. No UK tax on repatriation of profits

5.5. No tax on gain on sale of subsidiary (SSE)